In Olen Properties Corp. v. Moss, 981 So. 2d 515 (Fla. 4th DCA 2008), the Fourth District upheld a trial court's grant of class certification, holding that the putative class members satisfied rule 1.220(a)'s commonality requirement. 981 So. 2d at 519-20. There, the class representative and putative class members were tenants of the defendants. See id. In the class members' lease agreement with the defendants, there was a cancellation fee for early termination that equaled one monthly rent payment. See id. at 517. This fee was in the form of liquidated and not actual damages, and did not take into account mitigating factors in the defendants' recovery for a tenant's early termination. See id. When the class representative exercised her right to early termination, the defendants attempted to apply that provision, to which the class representative responded by filing a class action claim on behalf of herself and the other tenants. See id. The trial court granted class certification and the Fourth District affirmed. See id. It held that although the different tenants may have been subject to different fees than that of the class representative, this did not negate commonality, because the tenants still shared a common issue. See id. at 520. More specifically, the Fourth District held that commonality existed because at issue was not whether the types of fees were the same, but rather, whether the defendants' common practice of assessing liquidated damages as opposed to actual damages to the class members if they terminated their leases early was permissible. See id.